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Extraction Summary

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People
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Organizations
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Locations
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Events
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Relationships
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Quotes

Document Information

Type: Legal document (footnotes/citations page)
File Size: 851 KB
Summary

This document is a page of footnotes (numbered 7 through 23) from a larger legal memorandum or tax opinion included in the House Oversight Committee's release. It contains technical legal citations regarding U.S. tax code, specifically concerning the classification of business entities, trusts, 'Kintner Regulations,' QSub elections (Qualified Subchapter S Subsidiaries), and insurance companies. The latest date cited in the text is 1999, suggesting the document was created in or after that year.

People (2)

Name Role Context
Rothstein Case Law Subject
Cited in legal precedent: Rothstein, 54 AFTR 2d 84-5072
Kintner Case Law Subject
Cited in legal precedent defining regulations: case of Kintner, 46 AFTR 995

Organizations (5)

Name Type Context
House Oversight Committee
Source of the document release (Footer: HOUSE_OVERSIGHT_026593)
Internal Revenue Service (IRS)
Implied by citations of Revenue Rulings (Rev. Rul.) and Treasury Decisions (TD)
U.S. Congress
Cited in note 20: 106th Cong., 1st Sess.
Court of Appeals for the Second Circuit
Cited as (CA-2, 1984)
Court of Appeals for the Ninth Circuit
Cited as (CA-9, 1954)

Key Quotes (2)

"A business entity is any entity that is not a trust."
Source
HOUSE_OVERSIGHT_026593.jpg
Quote #1
"Certain types of corporations are not eligible to make a QSub election (e.g., insurance companies subject to tax under Subchapter L of the Code)."
Source
HOUSE_OVERSIGHT_026593.jpg
Quote #2

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